James Wilson Richmond, Jr. - Page 6

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          from 1999 to taxes petitioner owed for 1994 and applied only                
          petitioner’s three estimated tax payments for 2000 totaling                 
          $7,938.87 to petitioner’s 2000 tax liability, respondent                    
          determined that petitioner underpaid his taxes for 2000 by                  
          $3,152.35 ($11,091.22 - $7,938.87).  Respondent also assessed a             
          penalty for underpayment of estimated tax and interest.                     
               The transcript of petitioner’s 2000 taxes shows that on                
          November 5 and 12, 2001, respondent sent petitioner notices of              
          balance due for his 2000 taxes.  On July 30, 2002, petitioner               
          filed a petition for bankruptcy under 11 U.S.C chapter 7 seeking            
          discharge of his tax liabilities for 1992-95.  On November 13,              
          2002, the bankruptcy court granted petitioner a discharge of                
          those taxes.                                                                
               On October 14, 2003, respondent issued a Final Notice of               
          Intent to Levy and Notice of Right to a Hearing with respect to             
          petitioner’s 2000 tax liability.  Petitioner filed a timely                 
          request for a hearing.                                                      
               On March 24, 2004, Appeals Officer Jacquelyn Sansbury met              
          with petitioner.  Appeals Officer Sansbury had no prior                     
          involvement with regard to petitioner’s tax liabilities.  At the            
          meeting, petitioner asserted the proposed collection of the 2000            
          taxes was improper because the Internal Revenue Service (IRS)               
          ignored his direction to apply the 1999 overpayment to his 2000             
          estimated taxes.                                                            






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